SIKA UAE - Privacy Notice
Website Data Protection Notice
Notice describes how Sika UAE LLC, address P.O. Box 126212, Saih Shuaib 4 (533), Dubai Industrial City (DIC), Plot 61 (533-279), 126212, Dubai, United Arab Emirates ("Sika" or "we" or "us" or "our") as the legal entity responsible for the use of your personal data (Data Controller) processes the personal data and other information of the users ("you" or "your") in particular within the meaning of Federal Decree-Law No. 45 of 2021 of the United Arab Emirates on the Protection of Personal Data, together with any executive regulations, when issued and in force, or any guidance issued thereunder fromtime to time, as and when applicable (“UAE PDPL”) when using the website http://gcc.sika.com ("Website").
1. Categories of personal data, processing purposes, legal
basis and source
a. Personal Data actively provided by you:
If you create a user account on our Website, you will be asked to provide the following personal data about
you: Name, postal address, email address, selected password. Sika processes such personal data for the purpose of providing our services to you. Providing such personal data is voluntary. However, without providing such personal data, you will not be able to create a user account. The legal basis for the processing of such personal data is the necessity for the performance of a contract for the use of the Website, to which you are a party in accordance with Article 4(9) of the UAE PDPL.
If you register for the newsletter and consent to the receipt of newsletters and the processing of your email address for this purpose, you will be asked to provide your email address. We will use your email address for regularly sending you newsletters. Providing
your email address is voluntary. However, without providing your email address you will not receive newsletters. The legal basis for the processing of your personal data for sending newsletters is your consent (Art. 4 and 6 of UAE PDPL).
b. Other passively collected information:
In addition to the personal data that you actively provide, the Website may automatically collect, process and
store certain information on a pseudonymous basis from your computer or other electronic device:
● Device and usage information – that may include (i)
information specific to the used device to access the Website (including, but
not limited to, model, operating system, IP address, language, carrier and
similar information) and (ii) information about the use of features, functions,
or notifications on the device, to recognize you and to analyze trends. The
legal basis for this data processing is your
explicit consent (Art. 4 and 6 of the UAE PDPL), in
particular monitoring and maintenance of the Website performance;
● Website analytics – such as how often a user uses the
Website, aggregated usage, performance data. We use Website analytics to allow
us to better understand the functionality and use of our Website. The legal
basis for this data processing is your consent (Art. 4 and 6 of the UAE PDPL), in particular analysis of trends, usage and activities in
connection with our Website.
We also use cookies on the Website. For more information about cookies, please read our Cookie Notice,
available at [insert Cookie Notice URL], and manage your cookie preferences
through our Cookie Preference Center, available at [https://gcc.sika.com/en/cookie-policy.html].
2. Sale of Personal Data
Sika does not sell any personal data.
3. Recipients
a. Transfer to service providers
Sika may engage
external service providers, who act as a data processor of Sika, to provide certain services to Sika such as website service providers, marketing service
providers or IT support service providers. When providing such services, the
external service providers may have access to and/or may process your personal data.
Sika ensures that all such data processors are
bound by contractual obligations requiring them to
process personal data only in accordance with Sika’s documented instructions, to maintain confidentiality, to
implement appropriate technical and organizational security measures to
safeguard the personal data, and to process the personal data in compliance
with applicable data protection law, including the UAE PDPL.
b. Other recipients
Some of our colleagues administering the Website and
providing IT services may be employees of our group companies. When
administering the Website our colleagues may have access to and/or may process
your personal data. The respective transfer of your personal data is necessary to support the operation of the Website and related
services requested by you and is therefore required for the performance of the
contract concluded with you. (Art. 4(9) of UAE PDPL). The
access is limited to colleagues on a need-to-know basis.
Sika may also transfer your personal data to law enforcement agencies, governmental
authorities, legal counsel and external consultants in compliance with
UAE PDPL. The legal basis for such processing is compliance with a legal obligation to which Sika
is subject to (Art. 4(10) of the UAE PDPL), or to exercise or defend rights (Art. 4(3) of the UAE PDPL), or for other purposes explicitly permitted under the UAE PDPL. The updated list of data processors and third parties that we share data with is available upon request to Sika at the contact details below specified:
Data Protection Officer (DPO):
Name: Janice Gonsalves
Email: gonsalves.janice@ae.sika.com
Phone: +971 4 809 0800
4. Cross-border transfers of Personal Data
To support Sika’s business operations, group functions, IT infrastructure, and the
use of external service providers, your personal data and, where applicable,
sensitive personal data may be transferred to, accessed from, or otherwise
processed by recipients located outside the United Arab Emirates. In practice,
such transfers may occur where our Website is hosted, supported, or maintained
by IT or cloud service providers outside the UAE, where group-wide IT systems
or shared services are accessed by Sika group entities outside the UAE, or
where third-party analytics, marketing, or social media service providers
outside the United Arab Emirates process data in connection with Website
functionality or user interactions.
Any cross-border transfer of personal data is carried out in accordance with
Articles 22 and 23 of the UAE PDPL. Your personal data may be transferred to
recipients located in jurisdictions that provide an adequate level of personal
data protection or where a bilateral or multilateral data protection agreement
is in place, in accordance with Article 22 of the UAE PDPL.
Where your personal data is transferred to a jurisdiction that does not provide an
adequate level of protection, such transfer will occur only in permitted
circumstances under Article 23 of the UAE PDPL, including where:
● Appropriate contractual safeguards are in place requiring the recipient to protect the
personal data in accordance with UAE PDPL;
● You have provided explicit consent to the transfer;
● The transfer is necessary to perform a contract with you, to protect legal rights,
or to defend legal claims; or
● The transfer is required for international judicial cooperation or to protect the
public interest.
Security Measures
Sika implements appropriate technical and organizational measures to protect
personal data during cross-border transfers, including access controls,
confidentiality obligations, and data security measures proportionate to the
nature of the data and the associated risks. Access to personal data is
strictly limited to recipients who require such data for the purposes described
in this Website Data Protection Notice and who are subject to appropriate
confidentiality and data protection obligations. Further information regarding
cross-border data transfers and applicable safeguards may be obtained by
contacting Sika using the contact details provided in Section 8 below.
5. Links to social media profiles
On our website, we refer via
hyperlinks to social media profiles on third-party social networking platforms
(“Third-Party Platforms”). When you actively click on such a link, your
browser establishes a direct connection with the servers of the relevant
Third-Party Platform, as a result of which the platform provider becomes aware
of your visit to our website. If you are logged into the relevant Third-Party
Platform at the same time, the provider may associate your visit with your user
account.
In this context, personal data
may be transferred to and processed in jurisdictions outside the United Arab
Emirates. For further information on the processing of personal data, including
the use of cookies, tracking technologies, analytics, advertising, retargeting
tools, or similar technologies, you should refer to the privacy policy of the
relevant Third-Party Platform.
The purpose of linking our
website to Third-Party Platforms is to enhance the visibility of our website.
Clicking on a social media link is a voluntary action and is based on your
consent in accordance with Article 4(2) of the UAE PDPL. The legal basis for
any transfer of personal data outside the United Arab Emirates is your explicit
consent in accordance with Article 23(1)(b) of the UAE PDPL.
Sika does not control, monitor,
or determine the purposes or means of any personal data processing carried out
by Third-Party Platforms and shall not be responsible for their data processing
practices, security measures, or compliance with applicable data protection
laws. Use of such platforms is subject solely to the terms and privacy policies
of the respective platform operators.
Any access to or interaction with
Third-Party Platforms is undertaken at your own discretion and risk. To the
maximum extent permitted under applicable law, Sika shall not be liable for any
loss, damage, claim, or infringement arising out of or in connection with the
processing of personal data by Third-Party Platforms, including any
unauthorized access, misuse, or breach thereof.
For more information, please refer to Appendix II (Social media channels)
6. What rights do you have, and how can you assert your rights?
If you have declared your consent for any personal data processing activities, you can withdraw this consent at
any time with future effect. Such a withdrawal will not affect the lawfulness
of the processing prior to the consent withdrawal.
Subject to the conditions and limitations set out under the UAE PDPL, you may have the
right to:
● Right to receive Information (Art 13 of UAE PDPL);
● Right to request transfer of personal data (Art 14 of UAE PDPL);
● Right to correction or erasure of personal data (Art 15 of UAE PDPL);
● Right to restrict processing (Art 16 of UAE PDPL);
● Right to stop processing (Art 17 of UAE PDPL);
● Right to processing and automated processing (Art 18 of UAE PDPL)
Please note that the exercise of these rights may be subject to limitations or exemptions
under the UAE PDPL.
For further information on these
rights please refer to Appendix I [Your Rights].
If you have any concerns regarding the processing of your personal data, you are encouraged
to contact Sika’s Data Protection Officer using the contact details provided in
Section(8) below.
Where permitted under the UAE PDPL, you may also have the right to lodge a complaint
with the UAE Data Office designated under the UAE PDPL once such authority and
complaint procedures are formally established and operational.
To exercise your rights, please contact us as stated in
section (8) below or use the specific web-form “Exercise Your Privacy
Rights” available on the Sika’s Website.
Sika will respond to rights requests within 07
days, unless a longer period is permitted under applicable law.
7. How long do we keep your Personal Data?
Your personal data will be retained as long as necessary to provide you with the services requested. When Sika no longer needs to use your personal data to comply with contractual or statutory obligations or no legal basis for processing the data applies, we will remove it from our systems and records and/or take steps to properly anonymize it so that you can no longer be identified from it, unless we have to keep your information, including personal data, to comply with legal or regulatory obligations to which Sika is subject, e.g. statutory retention periods.
8. Contact us
If you have concerns or questions regarding this Website Data Protection Notice, please contact us as follows:
Data Protection Officer (DPO):
Name: Janice Gonsalves
Email: gonsalves.janice@ae.sika.com
Phone: +971 4 809 0800
Sika UAE LLC
P.O. Box 126212
Saih Shuaib 4 (533), Dubai Industrial City (DIC)
Plot 61 (533-279), Dubai, United Arab Emirates
Website:
http://gcc.sika.com
Appendix I: Your Rights
Right to receive information (Art 13 of UAE PDPL)
In accordance with Article 13 of UAE PDPL,
you have the right, by submitting a request Sika, to obtain the following
information:
a. Types of personal data
that are being processed and the purposes of processing;
b. Any decisions made on automated processing, including profiling.
c. The sectors or establishments with whom personal data will be
shared, both inside and outside UAE.
d. The controls and standards for the period of storage and
retention of personal data.
e. Protection measures for cross-border transfers under Articles
(22) and (23)
f. Measures to address any breach or misuse of personal data,
especially where it poses a serious threat to privacy or
confidentiality.
g. How to submit complaints to the competent authority (the UAE
Data Office/Bureau).
Your requests are generally free of charge.
However, Sika may charge a reasonable fee reflecting actual administrative
costs where permitted under the UAE PDPL, including where requests are
repetitive, excessive, or place an unreasonable burden on Sika.
You also have the right to receive information on how you may request correction,
erasure, restriction of processing, or object to processing of your personal
data.
We may refuse or limit requests where they
are repetitive, unrelated, conflict with investigations or judicial
procedures conducted by competent authorities, negatively affect information
security, or compromise the privacy of others.
Right to Request Transfer of Personal Data (Art 14 of UAE PDPL)
You may request a copy of your personal data in a machine-readable format where processing is based on
consent or contractual necessity and carried out by automated means. You may
also request a transfer of such data to another Controller where technically feasible.
Right to rectification (Art 15 of UAE PDPL)
You may request correction of inaccurate personal data or completion of incomplete personal data without undue delay
Right to erasure (Art 15 of UAE PDPL)
You have the right to request erasure of
your personal data held by us in the following cases:
a. If your personal data is no longer necessary for the purposes
for which it was collected,
b. If you have withdrawn your consent on which processing is based,
c. If you object to the processing and no legitimate reason exists
to continue processing, or
d. If your personal data has been processed in violation of the
UAE PDPL.
This right is subject to exceptions,
including where the data is required for public health purposes, ongoing
investigations, legal obligations, or other cases specified in the Executive
Regulations of the Federal Decree-Law No. 45 of 2021 of the United Arab
Emirates on the Protection of Personal Data.
Right to Restrict Processing (Art 16 of UAE PDPL)
You may request the restriction of theprocessing of your personal data in the following circumstances:
a. Where you contest the accuracy of your personal data, in which
case processing will be restricted for a specific period to allow Sika to
verify the accuracy of the data;
b. Where the processing is carried out for purposes other than those
for which the personal data was collected or otherwise lawfully agreed;
c. Where the processing is carried out in violation of the UAE PDPL
or other applicable data protection laws.
Your personal data may be retained after the completion of the processing purposes
where such retention is necessary for the exercise, or defense of legal claims.
Processing may nevertheless continue without your consent in the following cases, where
the processing is:
1. limited to the storage of personal Data,
2. necessary to pursue any of the procedures related to claiming
or defending rights and lawsuits or related to judicial proceedings.
3. necessary to protect the rights of third parties.
4. necessary to protect the public interest.
You will be notified if any restriction on processing is lifted.
Right to Stop Processing (Art 17 of UAE PDPL)
You may object to the processing of your personal data and ask us to stop processingit, particularly:
a. If the processing is intended for the purposes of direct marketing, including profiling related to direct marketing.
b. If processing is intended for statistical surveys unless required for the public interest, or
c. where the processing does not comply with Article (5) of the UAE PDPL.
Right Concerning Automated Processing (Article 18)
You may object to decisions based solely on automated processing, including
profiling, where such decisions have a legal or significant impact on you.
However, such an objection may not be accepted by Sika where processing is agreed upon
under a contract between you and Sika, is legally mandated, or the processing
is conducted based on your explicit consent.
Where automated decision-making is permitted, you have the right to request that
such decisions be reviewed with human intervention.
Appendix II: Social Media channels
We deploy links to the various social media channels on our website to promote our business
and advertise our products.
Depending on the social media channel and
services used, we might have access to personal data you provided, such as
personal information available at your social media profile. However, we do not collect or store such data, but use only data in
aggregated form (e.g. number of followers, number of likes, comments or shares)
for statistical and analytical purposes.
Meta Services
Sika uses Meta services, for which the
provider is:
Meta Platforms Ireland Limited
4 Grand Canal Square
Grand Canal Harbour
Dublin 2 Ireland
To find out more about Meta Privacy Policy,
which applies to most services and products offered by Meta, including Facebook
and Instagram, please visit:
https://www.facebook.com/privacy/policy
https://privacycenter.instagram.com/policy
1.1. Facebook Insights
For the administration of the Sika Facebook
Page, Sika is jointly responsible with Facebook for the processing of personal
data. In this context we might use “Facebook Insights” function to obtain anonymous statistical data on
visitors to our fun page. The statistics are performed using cookies which are
stored by Facebook on the visitor’s device. Information on which of the joint
controllers meet the obligations under the GDPR with regard to the processing
of page insights can be found in the Facebook’s Page Insight Controller
Addendum available under the link below. Please, note that the Addendum applies
to anyone administrating Facebook Page within the European Economic Area:
https://facebook.com/legal/terms/page_controller_addendum
The so-called "Meta pixel" function
is applicable when using the “Facebook Insights”. Meta pixel enables Facebook
to assign the Facebook visitors to certain groups for the display of specific
advertisements and to recognize them in this way. This ensures that these users
are only shown ads that are appropriate to their interests.
For more information about Meta pixel and how it works, visit https://www.facebook.com/business/help/651294705016616.
You can opt out of your Facebook pixel data
collection and use of it to display specific ads under the Settings section of
your Facebook account. Information about these settings can be found at https://www.facebook.com/settings?tab=ads (login required).
1.2. Marketing activities
If not indicated otherwise, our
processing of your personal data is based on our legitimate interest (Art.6
(1), f) GDPR) to provide you an answer to your messages or inquiries and to
analyze the reach and usage of social media channels which enable us to
optimize our presence on respective channels.
The legal basis for this data processing is your explicit consent,
where required under UAE PDPL.
We may include external services on our Facebook website, such as Sprinklr.
Facebook’s processing of your data:
Your personal Facebook settings at https://www.facebook.com/settings provide information about your information and allow you to correct
or submit it. To object to Facebook's processing or restrict data processing,
visit: https://www.facebook.com/help/contact/1994830130782319.
1.3. Contacting us
We use your Facebook account name when you
want to contact us through our Facebook page. You may voluntarily provide other
personal information. The data processing for the purpose of contacting us and
answering your inquiry is the consent you have voluntarily given. All personal
data collected in connection with your inquiry will be deleted after your
request has been processed, unless the storage is necessary for the
documentation of other processes (e.g. subsequent conclusion of contract).
Sika uses LinkedIn service, for which the provider is
● LinkedIn Ireland Unlimited Company, Wilton Plaza, Wilton
Place, Dublin 2, Ireland for users with their residence in the European Union,
European Economic Area and Switzerland or
● LinkedIn is LinkedIn Corporation, 2029 Stierlin Court Mountain View, CA 94043, United
States for users with their residence outside the European Union, European
Economic Area and Switzerland.
LinkedIn uses advertising cookies, which you
can deactivate using the following link:
https://www.linkedin.com/psettings/guest-controls/retargeting-opt-out
To find out more about LinkedIn Privacy Policy, please visit:
https://www.linkedin.com/legal/privacy-policy
Sika uses Twitter services, for which the provider is
● Twitter International Unlimited Company, One Cumberland
Place, Fenian Street Dublin 2, D02 AX07, Ireland, for users with their
residence in the European Union, EFTA States, or the United Kingdom or
● Twitter, Inc. 1355 Market Street, Suite 900, San
Francisco, CA 94103, for users with their residence in the United States or any
other country outside of the European Union, EFTA States, or the United
Kingdom.
To find out more about Twitter Privacy Policy, please visit:
https://twitter.com/privacy?lang=en
YouTube
Sika uses YouTube services, for which the provider is:
● Google Ireland Limited, Gordon House, Barrow Street,
Dublin 4, Ireland, for users with their residence in the European Economic Area
or Switzerland or
● Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA,
94043, USA
To find out more about YouTube Privacy Policy,
please visit:
https://policies.google.com/privacy